September 19 , 2014

US Department of Transportation Docket Operations West Building Ground Floor Room W

- 12

- 140 1200 New Jersey

Avenue, SE Washington, DC 20590

**RE: Docket FAA2014** 
**- 0387**  **Supplemental information Purchase of a Level C turbin**  **e device**

Dear Sir or Madam: US Aviation Group LL C , d/b/a US Aviation Academy has been assigned Docket # FAA2014

- 0387 as a result of our previous Exemption application on May 21, 2014. The exemption, if granted, would allow Chinese nationals employed b y Chinese Part 121 carriers that graduated from various US Aviation Academ y programs to take the FAA ATP (121) written knowledge test without meeting the requirements of 14 CFR part 61.35(a)(2) and 14 CFR Part 61.156(b). In further support of that Exemp tion request, US Aviation Group LL C has entered into a contract with Aeronautical Sy stems Engineering, Inc ( ASE ) , a Florida based simulator manufacturer, to acquire a new 14 CFR Part 60 approved Full Fl ight Simulator built to L evel C qualifications to further enhance the training conducted for Chinese nationals employed b y C hinese Part 121 air carriers. The device is scheduled for delivery and 14 CFR Part 60 certification in the second quarter of 2015. It will be a “change out” device with dual certificat ion as a Beechcraft King Air 350 and Beechcraft King Air C90A. ASE is a well known and proven supplier of this type of equipment and the work is well underway

over the past several months to produce the device on schedule. We fully expect an on time deli very of the device.As pointed out in our original Exemption request, 14 CFR Part 61.156(b) requires

the FSTD to represent a turbine aircraft with a take

- off weight of at least 40,000 pounds. Neither model of King Air represented b y the device being purc hased represents an aircraft that meets that weight requirement. As a result, even with this added purchase, US Aviation still needs an Exemption to the regulations already sited. US Aviation Academ y does not believe that the training value is in the we ight of the aircraft as much as it is in the avionics, systems, and level of training scenarios that can be conducted in such a device in a high level of controlled safety.



### IMPACT ON FLIGHT SAFETY The addition of the Level C Full Flight Simulator will allow training in a turbine aircraft that repli cates the training aircraft available in the FAA Approved flight training programs used in the Chinese training programs at this time by the Academy . Currently all Chinese cadets train for 20 hours in a King Air aircraft as the final course at the Academ y. Once the device is installed and approved, the CAAC will allow 10 of the 20 hours to be conducted in a Level C King Air flight simulator. High risk training that is currentl y conducted in the actual aircr aft can then be conducted safel y in the Level C flight simulator. In addition, many training events that could never be safely

conducted or actually

practiced in the real aircraft can be conducted easily in the flight simulator without danger to crew, equ ipment, or the general public as a whole . The increased intensity of training will produce a more proficient pilot with a better foundation of knowledge and experience to prepare them as they move into their roles as first offices in heavier turbine equipm ent with their respective airlines.



### IMPACT ON THE GENERAL PUBLIC **(14 CFR Part 11.71(a ) (**  **4))** At the present time, many of our Chinese airline customers are pulling their ATP training from all United States training providers since their cadets can not c omplete the FFS requirements of the new regulations that went into effect on August 1, 2014 as a perquisite of the ATP multi crew written knowledge test. Officials from the CAAC have traveled to Washington and have met with the FAA to outline the impact of the change in policy on their cadets training in the United States.



### SUMMARY US Aviation Group, LL C, is committed to providing a high quality US based training environment for Chinese national airline customers in a cost effective manner that allows the regulatory requirements of both countries to be met. The addition of ahigh qualit y Part 60 Level C Beechcraft King Air device in the immediate future will not

meet the 40,000 weight requirement of 14 CFR Part 61.156(b) , but it will meet the intent of the regulation b y exposing all cadets to effective training in a Level C turbine aircraft. The King Air was selected because it represent s the actual aircraft currentl y being used by US Aviation Group, LLC in the FAA Approved Turbine Transi tion flight co urse in use alread y b y US Aviation Academ y. All cadets complete the flight course after completing the FAA Approved 40 hour ATP and 130 hour Turbine Transition course s. We sincerel y believe that our request, when approved, will serve all parties best int erests, and still meet all of the intended regulations and safety concerns.
Respectfully

s ubmitted as additional information ,

Ray Heyde Vice President , General Manager US Aviation Academ y 4850 Spartan Drive Denton, TX 76207 rheyde@usaviationacademy .com 940

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